Illicit Finance: Agencies Could Better Assess Progress in Countering Criminal Activity

Fast Facts

Illegal funds from terrorism financing, human or drug trafficking, and other crimes can be moved and transferred through the U.S. financial system. Federal agencies often work together to combat this.

Lead agencies set government-wide strategies to coordinate and implement these efforts. We found that lead agencies often didn't clearly define goals for these efforts or collect relevant data to determine if goals were being met. This makes it harder for them to successfully address emerging challenges.

We made multiple recommendations, including that relevant agencies work together to develop joint goals and methods to assess progress.

Money counting machine counting money

Highlights

What GAO Found

Key federal agencies are responsible for investigating entities involved in illicit finance activities and referring them for federal prosecution. For example, the Federal Bureau of Investigation investigates transnational criminal organizations and associated money laundering efforts. Similarly, Immigration and Customs Enforcement's Homeland Security Investigations conducts investigations of criminal organizations in relation to cross-border movement of people, goods, and money. These federal law enforcement agencies and others often work together in interagency collaborative groups, such as task forces, that coordinate investigations of transnational organized crime, money laundering, and major drug trafficking networks. The Department of Justice prosecutes defendants accused of committing federal crimes, including those related to illicit finance.

Federal agencies are taking actions to implement selected government-wide strategies and efforts to counter illicit finance activities, but progress in implementation is not measured in some instances. In these cases, the strategies and efforts do not all have clearly defined goals, and lead agencies or entities do not regularly collect and assess relevant performance information tied to goals. For example, in the 2024 National Strategy for Combating Terrorist and Other Illicit Financing (Illicit Finance Strategy), the Department of the Treasury lists over 120 benchmarks (or goals) that agencies are generally implementing. However, Treasury does not collect and assess performance information from the implementing agencies to determine their progress against the goals. Similarly, entities leading the Presidential Initiative for Democratic Renewal (Initiative)—a set of policy and foreign assistance efforts to fight corruption, among other things—have not set joint performance goals or assessed whether agencies are achieving the goals. Such goals and assessments of performance information could help collaborating agencies ensure accountability for common outcomes and inform decisions, which would be in line with leading practices for evidence-based policymaking and interagency collaboration.

Extent That Selected Federal Strategies and Efforts Related to Countering Illicit Finance Activities Have Goals and Performance Information is Collected

Why GAO Did This Study

Criminal organizations generate money from illicit activities such as drug and human trafficking and launder the proceeds. Federal agencies investigate illicit activity and have developed several strategies and efforts to combat these crimes.

GAO was asked to review efforts to counter illicit finance activities. This report addresses, among other things, (1) selected agencies' roles and responsibilities in investigating and prosecuting illicit finance activities and (2) the progress made with selected strategies and efforts to counter illicit finance activities.

To address these objectives, GAO reviewed agency documents and data, including those related to eight selected federal strategies and efforts on countering illicit finance activities. GAO compared four of these strategies and efforts—which represent long-range, multiagency undertakings—to selected key practices for evidence-based policymaking and for interagency collaboration.

Recommendations

GAO is making four recommendations, including that Treasury collect and assess performance information on implementing the Illicit Finance Strategy, and that the Department of State and U.S. Agency for International Development establish goals and assess progress for implementing the Initiative. Treasury disagreed with the recommendation, State agreed with the intent of the recommendation but believes it already addressed it, and USAID agreed. The National Security Council did not provide comments.

Recommendations for Executive Action

Agency Affected	Recommendation	Status
Department of the Treasury	The Secretary of the Treasury should work with relevant agencies to implement a process for collecting and assessing evidence on the extent to which agencies are achieving the goals outlined in the National Strategy for Combating Terrorist and Other Illicit Financing. (Recommendation 1)	Open When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
National Security Council	The National Security Council, in its annual reporting of progress made against the United States Strategy on Countering Corruption's goals, should include reporting on metrics developed to measure progress against each strategic objective. (Recommendation 2)	Open When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
U.S. Agency for International Development	The USAID Administrator, in consultation with State and the National Security Council, should establish joint goals and a method to assess progress for implementing the Presidential Initiative for Democratic Renewal. (Recommendation 3)	Open When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
Department of State	The Secretary of State, in consultation with USAID and the National Security Council, should establish joint goals and a method to assess progress for implementing the Presidential Initiative for Democratic Renewal. (Recommendation 4)	Open When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.